Actual issues of introduction of anticorruption policy of the state: the administrative-legal aspect of Ukraine and international experience

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Kherson State University

Actual issues of introduction of anticorruption policy of the state: the administrative-legal aspect of Ukraine and international experience

Volkovych Olena Yuriivna

Reader of the Department of Administrative and Economic Law and Law Enforcement, Faculty of History and Law, Candidate of Legal Sciences

Kherson, Ukraine

Annotation

The urgent issues of the state development strategies are considered in relation to the solution of the issues of anti-corruption policy, the mechanism of the strategy of the development of anticorruption policy is explored, attention is paid to the clear understanding of certain norms of the Law of Ukraine "On Prevention of Corruption", which defines the concept of "potential conflict of interest".

Key words: «anti-corruption policy», «corruption», «conflict of interests», «strategy»

Introduction

Domestic science of administrative law at the beginning of the XXI century. is experiencing a difficult stage of formation, which is characterized by the determining influence of globalization and regional integration processes on the formation of the legal system of Ukraine. An understanding of one of the central legal categories of modern European administrative law - the European Administrative Area (EAA) - is important, as well as studying the system of its principles and basic elements [26, p.9-10]. So, in recent years in Ukraine, the practice of adopting "strategies" for certain spheres - energy, national and economic security, etc., has emerged. At the same time as a legal force, such strategies refer to subordinate legal acts. Examples of such strategies include the approved by the Cabinet of Ministers of Ukraine in recent years - the Strategy for the Reform of the Public Finances Management System for 2017-2020 (Order of 14 February 2017 No. 142-p.), The Strategy of the State Migration Policy of Ukraine for the period up to 2025 year (order dated July 12, 2017, No. 482-p.), Strategy of communications in the field Prevention and Counteraction (Order of August 23, 2017 No. 566-p.), or by the Presidential Decree - National Human Rights Strategy (Decree dated August 25, 2015, No. 501/2015), Strategy for the Reform of the Judiciary, Judiciary and Related legal institutes for 2015-2020 (decree of May 20, 2015, No. 276-2015) and others.

The questions of anti-corruption policy were given to the scientists of various branches and directions, in particular in the research: O.Y. Bousola, O.M. Dzhu- zhi, O.G. Kalman, B.V. Malyshev, SS Hasanova S.O. Kravchenko, I.B. Koliushka, IP Lopushinsky, VP Tymoshchuka, MI Havronyuk and others.

In most, these strategies are no less important to society than the Anticorruption Strategy. Prior to the adoption of certain strategies by laws, there are only two examples: only the Basic Principles (Strategy) of the State Environmental Policy of Ukraine for the period up to 2020 and the Principles of State Anti-Corruption Policy in Ukraine (Anticorruption Strategy) for 2014-2017 were approved by the laws of Ukraine . These considered bills, however, again assume approval of the Anti-corruption strategy by adopting the relevant Law of Ukraine.

According to Clause 6 of Article 85 of the Constitution of Ukraine, it was stipulated that the powers of the Verkhovna Rada of Ukraine include the approval of national programs of economic, scientific, technical, social, national and cultural development, and environmental protection [2], in particular, according to Part 2 of Art. 85 The Verkhovna Rada of Ukraine also exercises other powers that are assigned to it in accordance with the Constitution of Ukraine [2].

Laws "On State Forecasting and Development of the Program of Economic and Social Development of Ukraine" and "On State Target Programs" establish the legal, economic and organizational principles for the formation of a system of relevant forecast and program documents, in particular: the general procedure for their development, approval and implementation. The procedure for the adoption of such documents is provided for in the Law "On State target programs, and is a request for the adoption of such programs. State target programs are divided into national and other programs (the purpose of the latter is to solve certain problems of the development of the economy and society or certain sectors in need of state support).

In accordance with Part 2 of Article 2 of the Law of Ukraine "On State Target Programs", the state target program is developed in the aggregate of the following conditions [3]:

-the existence of a problem that is impossible to solve by means of territorial or branch management and requires state support, coordination of activities of central and local executive authorities and local self-government bodies;

-correspondence of the program's purpose to the priority directions of the state policy;

- the need for inter-branch and interregional links between technologically related industries and industries;

-availability of the real possibility of resource support for the implementation of the program.

The mentioned documents do not use a separate notion of "strategy" as a type of program-forecast document. In the Law "On State Forecasting and Development of Programs of Economic and Social Development of Ukraine" [4], definitions that the forecast of economic and social development is a means of justifying the choice of a particular strategy and the adoption of specific decisions by the relevant authorities on the regulation of socio-economic processes. That is, the interpretation of the term "strategy" 1) is the art of economic, political leadership of the masses, which should determine the main direction of their actions, actions; 2) the way of action, line of conduct [5, pp. 834-835]. According to Art. 10 of the above-mentioned Law, the national programs of economic, scientific, technical, social, national-cultural development, environmental protection, upon submission of the Cabinet of Ministers of Ukraine, are approved by law [4]

This is confirmed by the fact that the Cabinet of Ministers of Ukraine, however, had to develop and adopt in addition to this strategy the State Program on implementation of the principles of state anti-corruption policy in Ukraine (Anticorruption Policy) for 2015-2017 (resolution dated April 29, 2015, No. 265), the majority of provisions of which duplicate the AntiCorruption Strategy. Thus, the interpretation of the word "politics" has a different meaning, in particular: the goals and objectives of social classes in the struggle for their interests; methods and means of achieving these goals and objectives; the general direction, the nature of the activities of the state, a political party in one or another field in a certain period; events and issues of national and international public life [15, p.776-777]. Interpretation of the term "corruption" is a negative social phenomenon, above all, the abuse of state power for its own benefit and the damage to the legal, moral principles of the functioning of society. more detailed is the definition of corruption in the American-Ameri- can Convention against Corruption, adopted by the Organization of American States on March 29, 1996: "corruption is an attempt to get directly or indirectly by a government official or a person who performs public functions for any items of monetary value as well as other benefits, such as a gift, a service, a promise, an advantage for himself or another person or organization in exchange for any act or omission in the performance of his public functions; is a proposal or provision of such benefit directly or indirectly; It is any act or omission in the performance of its duties by a government official or a person performing public functions for the purpose of unlawfully making a profit for himself or a third party; is a fraudulent use or concealment of property obtained as a result of one of these acts "[6, P.86].

So, the domestic law also defines the definition of "corruption" in the Law of Ukraine "On the Prevention of Corruption" - the use by a person specified in Clause 1 of Article 3 of this Law of the powers granted to it or the related capabilities in order to obtain unlawful gain or adoption such a gain or acceptance of the promise / offer of such benefit for himself or other persons or, accordingly, the promise / offer or provision of unlawful benefit to a person specified in part 1 of article 3 of the Law or on his request to other natural or legal persons for the purpose of a slope take that person to the wrongful use of the provision of his or her official powers or capabilities related thereto. Thus, we noted above that the property of corruption is that it penetrates into all spheres of public life and relates to most social relations, especially those with inherent dismissive-administrative features. But the important point is that, at the present stage, corruption has spread its negative impact on those social relations that, it would seem, did not have such high corruption risks.

The statement stated that the approval of the given document, which has the features of the state target program but is not a national program of economic, scientific and technical, social, national-cultural development or environmental protection, is not exactly in line with the requirements of the Constitution of Ukraine and the Law "On State targeted programs. " If in 2014, during the post-revolutionary wave, it was important to focus the attention of society on the complex of anticorruption measures, and it is generally doubtful that in the future, every three or four years, the Verkhovna Rada of Ukraine should adopt a new anti-corruption strategy precisely by law. Yes, this question requires a special discussion.

Particularly acute today is the issue of the existence of political and high-level corruption, poses a serious threat to the national security of Ukraine and is a breeding ground for other forms of corruption. As R. Chapko notes, "power is corrupt, and absolute power corrupts absolutely", their interrelation is self-serving not only materially. It is the political component that ensures any corruption of the cover and allows its participants to avoid responsibility [21, p. 8]. Political corruption, which involves the unlawful use by participants in the political process and the media of public authority of their capabilities and powers to obtain personal or group benefits, generates corruption schemes at all levels of economic and social life. Until recently, corruption remained the most profitable and least risky business in Ukraine. The high level of corruption is noted in the field of public procurement, land relations, construction, trade, mining industry. Shadow schemes in these sectors are supported by officials and politicians [5]. Thus, the French researcher Marcel Moss, apparently, was the first to emphasize the social rather than the economic origin of this form of social interaction as an exchange of gifts [7, p.69-76]. At the same time, the exchange itself serves not merely as an economic transaction, but as a thing in itself as a kind of benefit, usually in the form of personal or personal relations: the exchange of gifts consists of two elements - the loss of trade and the respect that constituted the foundation of the economy of gifts. Thus, the very term of the gift - obliges the person who adopted it - to satisfy certain benefits (material, social, economic, political) in relation to the donor.

Turning to official indicators of corruption perception for 2018, it is noted that Ukraine has improved its performance over this period. Her result is points and 120th among 180 countries. Thus, Ukraine gained another 2 points and climbed to 10 places (the result for 2017 - 30 points, 130 place). Ukraine from among its neighbors was able to bypass only the Russian Federation (28 points, 138th place). Instead, the rest have higher scores: Poland - 60, Slovakia - 50, Romania - 47, Hungary - 46, Belarus - 44, Moldova - 33 points [13].

The phenomenon of corruption is so absorbed by the whole society, that there is a need to distinguish certain guiding principles for its detection in order to seek ways of its prevention and termination. The absence of identical models of the structure and operation of the SAASP does not mean that there are no general guidelines governing the functioning of anticorruption agencies. Thus, in the Resolution of the Council of Europe "On Twenty Guiding Principles on Combating Corruption", adopted in 1997, it has been determined that the independence of an institution must be one of the cornerstones of the effective fight against corruption (taking into account the prevention component) [11].

In the Criminal Law Convention on Corruption, prepared by the Council of Europe in 1999 (and Ukraine ratified it in 2006) [14], this principle is further elaborated. In particular, the provisions of Article 20 of the Convention provide for independence, autonomy, the obligation of States to specialize in the staff and bodies in the fight against corruption and ensure adequate funding for the effective execution of their tasks.

In general, the provisions of international conventions, recommendations and guidelines on basic principles (institutional autonomy, mandate, resources and enabling environment) are very similar. At the same time, as noted above, a review of practice shows that the implementation of these principles occurs through different approaches and means.

In accordance with Recommendation No. R (2000) 10 of the Committee of Ministers to member states of the Council of Europe on codes of conduct for civil servants, the Model Code of Conduct for Civil Servants, in particular Art. 8 stipulates that a civil servant should not allow his or her personal interests to be in conflict with his or her public office. Avoiding such conflicts of real, potential or potential is his or her responsibility. A civil servant should not abuse his position in favor of his personal interests [16].

Thus, in accordance with Article 1 of the Law of Ukraine "On Prevention of Corruption", the notion "potential conflict of interests" is defined - the presence of a person's private interest in the sphere in which it performs its official or representative powers, which may affect the objectivity or impartiality of adoption her decisions, or for the commission or non-execution of actions in the exercise of these powers [17]. In accordance with the Instruction of the Air Force post dated May 22, 2017, No. 223-943 / 0 / 4-17, the potential conflict of interests differs from the real one in that when a potential conflict establishes only the existence, existence of a private interest of the person that may affect objectivity or non-bias the adoption of decisions by it, whereas in the case of a real conflict of interests, the existing conflict between an existing private interest of a person and his official or representative powers directly affects (objectively) impartiality of decision-making, for in committing or non committing acts during the execution of these powers. However, in disclosing the content of the concept of "potential conflict of interest", in our opinion, it is not enough to assert that a public servant has only a private interest in the sphere in which he performs his duties.

Since the emergence of a potential civil servant in a potential conflict of interest is the reason for the consequences for him to occur, the study of the concept of "potential conflict of interest" should be clear, that is, that which does not allow ambiguous interpretation. At the same time, the presence in the person of only a private interest in the sphere in which the person carries out official duties, in order to qualify the emergence of a potential conflict of interest, may lead to ambiguity, especially as regards civil servants of senior positions. For any person it is characteristic of the presence of private interest, in some cases, the civil servant may not know about its occurrence, and therefore, to qualify the presence of a public servant as a potential conflict of interests, it is necessary to establish and the presence of other elements.

For example, the jurisprudence gives a clearer interpretation of the provisions of Article 172-8 of the Code of Administrative Offenses violating the requirements for the prevention and settlement of conflicts of interest. So when considering the cases of committing an administrative offense, stipulated in Part 2 of Art. 172-8 Code of Ukraine on Administrative Offenses (taking actions or taking decisions in a situation of real conflict of interests) courts must take into account the necessity of having facts, the establishment of which should be reflected in the protocol on the administrative offense and in the ruling of the court: strategy anticorruption international

the existence of the private interest of the offender, which should be clearly articulated and determined;

the existence of a contradiction between the private interest and the official or representative powers, indicating the extent to which this contradiction is manifested or influenced by the decision;

the presence of authority to make a decision;

the existence of the actual effect of the contradiction between private and official or representative interest in the objectivity or impartiality of the decision [20].

The court explained that in order to establish the fact of a real conflict of interests it is not sufficient to state the existence of a private interest that could potentially affect the objectivity or impartiality of decisionmaking, but it should be directly established that, first, there is private interest, and secondly, it contradicts official or representative powers, and thirdly, such a contradiction can not affect, but actually affects the objectivity or impartiality of decision-making or action [19].

The subject of administrative misconduct - a special one, that is, one who has the power of authority, refers to such legislation:

persons authorized to perform functions of the state or local self-government:

a) the President of Ukraine, the Chairman of the Verkhovna Rada of Ukraine, his First Deputy and Deputy. Prime Minister of Ukraine, First Vice Prime Minister of Ukraine, Vice Prime Ministers of Ukraine, ministers, other heads of central executive bodies that are not members of the Cabinet of Ministers of Ukraine, and their deputies, Head of the Service Security of Ukraine, Prosecutor General of Ukraine, Head of the National Bank of Ukraine, Chairman of the Accounting Chamber, Ukrainian Parliament Commissioner for Human Rights. Chairman of the Verkhovna Rada of the Autonomous Republic of Crimea, Chairman of the Council of Ministers of the Autonomous Republic of Crimea;

people's deputies of Ukraine, deputies of the Verkhovna Rada of the Autonomous Republic of Crimea, deputies of local councils;

civil servants, local self-government officials;

military officers of the Armed Forces of Ukraine and other military formations formed in accordance with the laws;

judges of the Constitutional Court of Ukraine, other professional judges, Chairman, members, disciplinary inspectors of the High Qualifications Commission of Judges of Ukraine, officials of the secretariat of this Commission, Chairman, Vice-Chairman, secretaries of sections of the High Council of Justice, as well as other members of the High Council of Justice, people's assessors and jurors (when performing these functions);

persons of ordinary and commanding members of the organs of internal affairs, state criminal-executive service, bodies and subdivisions of civil protection, the State Service for Special Communications and Information Protection of Ukraine, persons of the executive staff of the tax militia;

e) officials and officers of the Prosecutor's Office, the Security Service of Ukraine, the diplomatic service, the customs service, the State Tax Service;

e) members of the Central Election Commission;

g) officials and officers of other bodies of state power;

persons who, for the purposes of this Law, are equated with persons authorized to perform functions of the state or local self-government:

officials of legal entities of public law who are not specified in paragraph 1 of part one of this article, but who receive wages at the expense of the state or local budget;

persons who are not civil servants, officials of local self-government but provide public services (auditors, notaries, appraisers, as well as experts, arbitration managers, independent intermediaries, members of labor arbitration, arbitration judges while performing these functions, others persons in cases established by law).

Thus, corruption and distrust in the judiciary lead the barrier to attracting investment to our country for three consecutive years. Without significant approaches in the field of anti-corruption measures, Ukraine will not be able to significantly improve its welfare. Ukrainian voters identified corruption as one of the three biggest problems in Ukraine. The biggest threat to politics is called political corruption, according to more than 90 percent of Ukrainian citizens [24].

Also, Superior specialized court of Ukraine noted that the administrative penalty for committing a corruption offense may be imposed within three months from the date of detection, but not later than two years from the date of its commission (Part 3 of Article 38 of the Code of Administrative Offenses). It is not stipulated by the law to extend the time limits for imposition of administrative penalties, therefore, in case of their termination, proceedings in the case are closed.

For example, Person 1 is an official of a state- owned enterprise under the jurisdiction of which the person 2 is employed. These persons were spouses and are currently divorced (the person initiating the divorce was Person 1), that is, in the past, they were related to a family relationship. Person 1, feeling guilty before Face 2 for divorce, when making decisions of a regulatory nature Personality 2 puts in a more privileged position than other employees (assigns the largest amount of premiums, while forming a vacation schedule, firstly takes into account the wishes for the holidays Person 2, with the assignment of orders among employees of the enterprise, gives easy assignment to Person 2, etc.).

The law does not impose any restrictions or restrictions on the existence of private interests as such. It is about observance of the rules of an employee's ethical behavior and an appropriate assessment of private interests through the prism of their possible negative impact on the objectivity of decision-making or actions of an official in the exercise of his official or representative powers.

In accordance with the current legislation of Ukraine, an algorithm of action of a person is fixed in connection with the emergence of a conflict of interests in it. The law obliges to take measures to prevent the emergence of a real, potential conflict of interest. From the moment when the persons specified in clauses 1 and 2 of the first part of Article 3 of the Law have found out whether they should have found out whether they have a real or potential conflict of interests, they are obliged to inform the direct manager not later than the next working day, and if the person is in a position that does not involve the presence of a direct supervisor or a collegial body - the National Agency or another body or collegial body determined by law, during the exercise of powers in which a conflict of interest has arisen [18].

The success of the anti-corruption policy is an important part of the implementation of the Association Agreement. The National Agency for the Prevention of Corruption, in cooperation with the registry owners, has approved the terms of reference and agreed protocols for the automated exchange of information necessary for verification of declarations. Since September 2018 the system of logical and arithmetic control of e- declarations has begun.

The issue of compulsory declaration for representatives of anti-corruption non-governmental organizations, which is subject to active public discussion, is under consideration by the Constitutional Court of Ukraine. According to the Verkhovna Rada Commissioner for Human Rights and People's Deputies, proceedings on the constitutionality of certain provisions of the Law of Ukraine "On Prevention of Corruption" were opened. For the adoption of the Law "On the Highest Anti-Corruption Court" in June 2018, the creation of a specialized court began. The government provided the premises, and in August 2018 announced a competition for vacancies in the High Anti-Corruption Court and the Court of Appeal. Since November 2018, the Public Council of International Experts has begun.

Thanks to financial independence, the Higher Anti-Corruption Court would be able to independently plan its activities. It was envisaged that the amount of financing of the Appeals Chamber of the Higher AntiCorruption Court will be specified separately in the State Budget of Ukraine, which increases its independence, even within individual chambers. After familiarizing themselves with the Anti-Corruption Strategy for 2018-2020, international and domestic experts on state anti-corruption policy came to the conclusion that anticorruption strategy in this form is not capable of achieving significant progress in the implementation of anticorruption reform in Ukraine [9].

Thus, in Ukraine the second year has not been the main strategic document in the field of prevention and fight against corruption. In such circumstances, anticorruption institutions are unbalanced and ineffective, while other state bodies and local self-government bodies carry out those anti-corruption measures that they consider appropriate (in an intuitive way) or do not take any action in this area at all. The situation seems to satisfy everyone: both the authorities and the corrupt and corrupt officials in power.

Conclusions. in general, the situation with the implementation of Ukraine recommendations of international organizations in the period 2014-2018 can be characterized by two main trends: 1) regulatory approximation to the requirements of international standards; 2) the implementation of many progressive provisions of the new anti-corruption legislation in practice is hampered mainly by various factors, the main of which is the lack of political will in the executive and law enforcement agencies.

To date, these measures remain unfulfilled, many of them are of a superficial nature. Therefore, it is extremely important that this year the national anti-corruption policy should undergo radical changes that should be aimed at the effective implementation of anticorruption legislation, the State Anti-Corruption Policy (Anti-Corruption Strategy) for 2014-2017.

The Government's priority action plan for 2017 provided for the Government to address five challenges. Only three of the five planned tasks of the Government managed to at least partially solve. No anticorruption measures aimed at solving two other tasks will be taken in 2017. As of February 1, 2019, 12 anticorruption measures remain unrealized. Also, in the Government's Priority Action Plan for 2018, the Government has set itself the target of five tasks. As of February 1, 2019, only one of five of these areas succeeded in implementing all planned activities. In this case, they are not implemented by the Government, but - the National Agency for the Prevention of Corruption (NACC). In three directions, the Government managed to implement only a few of the anti-corruption measures planned, and no other anticorruption measures were taken [25].

In 2014-2018, the Parliament has proven to be a very productive body in the field of anti-corruption policy-making, since it has adopted all the basic anti-corruption laws and the absolute majority of those anticorruption laws that came to it for consideration. However, the anti-corruption policy of the Parliament was not based on an assessment of the previous anti-corruption policy and a comprehensive analysis of the current situation in the relevant area, and therefore, in some cases, its effectiveness was low [25].

Today, the authorities should make every effort to overcome those negative phenomena that impede the implementation of anti-corruption legislation, to direct efforts to implement those measures that are to be implemented in accordance with the provisions of the State Anti-Corruption Policy for 2014-2017. Summarizing the above, it should be noted that effective fight against corruption, implementation of measures of state anti-corruption policy in the state is impossible without the political will of its key carriers - the head of state as a person of the President of Ukraine, the government, parliament, factions of political forces. To this end, all measures aimed at the successful implementation of the provisions of the State Anti-Corruption Policy (Anticorruption Strategy) for 2014-2017 and ensuring the effective functioning of the newly created anti-corruption actors - the National Anti-Corruption Bureau, the National Agency for the Prevention and Counteraction of Corruption, National Anti-Corruption Policy Council.

References

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